State v. Williams
2016 Ohio 5403
| Ohio Ct. App. | 2016Background
- In Aug. 2014 Morace Williams was indicted after a group dispute at an East 40th Street apartment; charges included counts of improperly discharging a firearm (Counts 1–3) and felonious assault with firearm specifications (Counts 4–13). Six victims were children.
- At trial prosecution relied principally on Rayleen Patterson (eyewitness) and a 911 caller who described two males, one (Williams) handing a gun to the other (Shelton), after which shooting occurred. Jury acquitted on Counts 1–3 but convicted Williams on Counts 4–13 (felonious assault with firearm specs).
- Several defense witnesses (Grove, Braxton, Borich, Jackson) either recanted, gave inconsistent statements, or denied seeing Williams with a gun; some admitted lying or being influenced.
- Williams moved for acquittal (Crim.R. 29) and later moved for a new trial based on newly discovered evidence: a private investigator’s affidavit purporting to record statements by Shelton and Jackson that Williams did not possess or hand over a gun and that Shelton did all the shooting. The trial court denied both motions.
- Sentencing: concurrent two-year terms on base counts, merged one-year specs into three-year specs, with two consecutive three-year specs applied so total effective sentence was eight years (judicial release considered after six years). Williams appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency / denial of Crim.R. 29 motion (felonious assault via complicity) | State: Evidence (Patterson, 911 caller, other testimony) permits inference Williams aided/abetted Shelton by bringing group, firing, handing gun, and driving getaway — sufficient for conviction | Williams: No evidence he aided/abetted; others testified they did not see him with a gun; Shelton acted impulsively | Affirmed — viewed in light most favorable to prosecution, reasonable juror could find Williams knowingly aided/abetted (R.C. 2923.03) |
| Manifest weight of the evidence (credibility of witnesses) | State: Jury entitled to credit Patterson and 911 call; defense witnesses were inconsistent or motivated to lie; credibility issues for jury to resolve | Williams: Patterson was unreliable; other witnesses contradicted prosecution theory, so verdict against manifest weight | Affirmed — appellate court defers to jury credibility determinations; conviction not a manifest miscarriage of justice |
| Motion for new trial based on newly discovered evidence (Crim.R. 33(A)(6)) | State: Investigator’s affidavit is hearsay, cumulative, and fails Petro factors; Jackson and Shelton identifiable and available pretrial | Williams: Investigator’s affidavit recounts Shelton/Jackson statements exculpating Williams and establishing actual innocence | Affirmed — trial court did not abuse discretion; affidavit lacked showing of strong probability of different result, was cumulative/contradicted trial testimony, and due diligence issues existed |
Key Cases Cited
- State v. Bridgeman, 55 Ohio St.2d 261 (legal sufficiency standard)
- State v. Apanovitch, 33 Ohio St.3d 19 (Crim.R. 29 grant standard)
- State v. Diar, 120 Ohio St.3d 460 (Jackson v. Virginia / Jenks standard for sufficiency)
- State v. Jenks, 61 Ohio St.3d 259 (standard for reviewing sufficiency)
- State v. Johnson, 93 Ohio St.3d 240 (elements of aiding and abetting)
- State v. Cartellone, 3 Ohio App.3d 145 (circumstantial evidence and participation inference)
- State v. Trocodaro, 36 Ohio App.2d 1 (overt acts like driving getaway car as aiding/abetting)
- State v. Thompkins, 78 Ohio St.3d 380 (manifest-weight standard)
- State v. Wilson, 113 Ohio St.3d 382 (guidance on weighing evidence)
- State v. Petro, 148 Ohio St. 505 (factors for newly discovered evidence/new-trial motions)
- State v. Schiebel, 55 Ohio St.3d 71 (standard of review for new-trial denial)